Text

License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF 477, Revision 3
	ML13247A659
Person / Time
Site:	Columbia
Issue date:	07/25/2013
From:	Hettel W; Energy Northwest
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	G02-13-104
	Download: ML13247A659 (15)
	v • d • e

W.Grover Haelte

) ENERGY Cumbla Generating Staton P.O. Box 968. PE23 NORTHW EST Richtand., WA 99352-0968 Ph. 509.377 83111 F. 509.377.4150 wghettel@energy-noqthwest.com July 25, 2013 10 CFR 50.90 G02-13-104 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 UCENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF 477, REVISION 3

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 C FR), Energy Northwest is submitting a request for an amendment to the Technical Specifications (TS) for Columbia Generating Station (Columbia).

The proposed amendment would revise the TS requirements by revising the Required Action and associated Completion Time for two inoperable control room air conditioning (AC) subsystems. The proposed changes are consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-477, Revision 3. The availability of this TS Improvement was announced in the FederalRegister on March 26, 2007, (72 FR 14143) as part of the consolidated line Item improvement process (CLIIP).

The following attachments are included in support of this request:

" Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant specification verifications,

" Attachment 2 provides the existing TS pages marked up to show the proposed change.

" Attachment 3 provides revised (clean) TS pages.

" Attachment 4 provides the existing TS Bases pages marked up to show the proposed change In accordance with 10 CFR 50.36(a).

There are no new regulatory commitments contained in this request.

Energy Northwest requests approval of the proposed License Amendment within one year of the date of this letter with the amendment being implemented within 60 days thereafter.

In accordance with 10 CFR 50.91, a copy of this application with attachments, is being ,40(.) (

provided to the designated Washington State Official. ,t 6L-Pr-) s/8c

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 Page 2 of 2 If you should have any questions regarding this submittal, please contact Ms. L. L.

Williams at 509-377-8148.

I declare under penalty of peujury under the laws of the United States of America that I am authorized by Energy Northwest to make this request and that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, W. G. Hettel Vice President, Operations Attachments: As stated cc: NRC Region IV Administrator AJ Rapacz - BPA1 399 NRC NRR Project Manager WA Horin - Winston & Strawn NRC Sr. Resident Inspector - 988C RR Cowley -WDOH JO Luce - EFSEC

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 Page I of 3 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify the Columbia Generating Station (Columbia)

Technical Specifications (TS) requirements by revising the Required Action and associated Completion Time for two inoperable control room air conditioning (AC) subsystems. The Control Room AC System is subject to Limiting Condition for Operation (LCO) 3.7.4. The revised Action allows a finite time to restore one control room AC subsystem to operable status and requires verification that control room temperature remains < 90°F every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Traveler TSTF-477, Revision 3. The availability of the TS improvement was published in the FederalRegisteron March 26, 2007, (72 FR 14143) as part of the consolidated line item improvement process (CLIlP).

The corresponding Safety Evaluation (SE) and No Significant Hazards Consideration (NSHC) determination were published in the FederalRegisteron December 18, 2006, (71 FR 75774).

2.0 ASSESSMENT 2.1 Applicability of TSTF-477, and Published Safety Evaluation Energy Northwest has reviewed TSTF-477, Revision 3 (Reference 1), and the NRC model SE (Reference 2) as part of the CLIIP. Energy Northwest has concluded that the information in TSTF-477, as well as the SE prepared by the NRC staff, are applicable to Columbia and justify this amendment for the incorporation of the changes to Columbia's TS.

2.2 Optional Changes and Variations Energy Northwest is not proposing any variations or deviations from the TS changes described in the TSTF-477,Revision 3 or the NRC staff's model SE. All changes included in the TSTF have been incorporated into Columbia's proposed changes.

Columbia's TS for the Control Room AC System differ from the BWR/4 and BWR/6 Standard Technical Specifications (STS) contained in TSTF-477, Revision 3. On November 27, 2006, the NRC issued Amendment 199 (Reference 3) to Columbia's Operating License that incorporated the application of Alternative Source Term (AST) methodology for design basis radiological accidents. Within that Amendment, TS 3.7.4, "Control Room Air Conditioning (AC) System" was modified as follows:

"During movement of irradiated fuel assemblies in the secondary containment," and "During CORE ALTERATIONS," were deleted from the applicability statement.

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 Attachment 1 Page 2 of 3 Coordinating deletions were made to conditions and actions that involved movement of irradiated fuel assemblies.

The changes in Amendment 199 were approved based on the fact that isolation is not credited for the mitigation of the AST Fuel Handling Accident, and thus, the operability of the Control Room AC System during core alterations or fuel handling activities is no longer necessary.

As a result of the changes from Amendment 199, the dean and marked up versions of Columbia's TS do not show any conditions or actions related to movement of irradiated fuel assemblies. While the STS markups in TSTF-477 include this content, that content is not being changed by TSTF-477; hence, this Is not considered a deviation from the TSTF.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Energy Northwest has reviewed the proposed no significant hazards consideration (NSHC) determination published in the FederalRegister as part of the CLIIP. Energy Northwest has concluded that the proposed NSHC presented in the FederalRegister notice is applicable to Columbia and is hereby Incorporated by reference to satisfy the requirements of 10 CFR 50.91(a),

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegisteron March 26, 2007, (72 FR 14143) for this TS improvement, plant-specific verifications were performed as follows:

Energy Northwest has reviewed References 1 and 2. Columbia has utilized References 1 and 2 to develop the proposed TS changes. The changes contained in this license amendment request are derived from those applied to STS 3.7.5 for BWR/4 in TSTF-477.

Energy Northwest has also concluded that the justification presented in TSTF-477, Revision 3 and the model SE prepared by the NRC staff is applicable to Columbia, and Justify this amendment for the incorporation of the changes to the Columbia TS.

In addition, Energy Northwest has proposed TS Bases consistent with TSTF-477, which provide guidance and details on how to implement the new requirements. Finally, Columbia has a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION This amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF.477, Rev 3, involves no significant

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 Page 3 of 3 increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-477, Rev 3, involves no significant hazards considerations, and there has been no public comment on the finding in FederalRegisterNotice 71 FR 75774, December 18, 2006. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth In 10 CFR 51.22(c) (9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance .ofthe amendment.

5.0 REFERENCES

1. TSTF-477, Revision 3, "Adding an Action Statement for Two Inoperable Control Room Air Conditioning Subsystems".

2. NRC Model Safety Evaluation Report, 71 FR 75774, dated December 18, 2006.

3. Letter dated November 27, 2006, B. Benney (NRC) to JV Parrish (Energy Northwest), "Columbia Generation Station - Issuance of Amendment Re:

Alternative Source Term". [ADAMS Accession No. ML063280053]

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UPS)

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable, subsystem to OPERABLE status.

B. Two control room AC B.1 Verify control room area Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystems inoperable, temperature < 900 F.

AND B.2 Restore one control room 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AC subsystem to OPERABLE status.

BC.Required Action and 8C.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i associated Completion I Time of Condition A or B AND not met in MODE 1, 2, I or 3. 8C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months GD. Required Action and GDA1 Place OPERABLE control Immediately associated Completion room AC subsystem in Time of Condition A not operation.

met during OPDRVs.

OR GD.2 Initiate action to suspend Immediately OPDRVs, Columbia Generating Station 3.7.4-1 Amendment No. 460,400 225

Lb.

Control Room AC System 3.7.4 CONDITION REQUIRED ACTION COMPLETION TIME D.--Two eonro 'oon ,AC A4---leC-1 Q3 QA-4

,tbY64erPG.44*pe;eab18 Columbia Generating Station 3.7.4-2 Amendment No. 469,499 225

Control Room AC System 3.7.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to suspend Immediately associated Completion OPDRVs.

Time of Condition B not met Two,-onlooen A4bb6ys*ems

,ppefabe-during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the 24 months capability to remove the assumed heat load.

Columbia Generating Station 3.7.4-3 Amendment No. 46.,49. 225

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN)

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem Inoperable. subsystem to OPERABLE status.

B. Two control room AC B.1 Verify control room area Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months subsystems inoperable, temperature < 90°F.

AND B.2 Restore one control room 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AC subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I.

associated Completion Time of Condition A or B AND not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Place OPERABLE control Immediately associated Completion room AC subsystem in Time of Condition A not operation, met during OPDRVs.

OR D.2 Initiate action to suspend Immediately OPDRVs.

Columbia Generating Station 3.7.4-1 Amendment No. 4.69,4.99 225

Control Room AC System 3.7.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to suspend Immediately associated Completion OPDRVs.

Time of Condition B not met during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the 24 months capability to remove the assumed heat load.

Columbia Generating Station 3.7.4-2 Amendment No. 4 W,400 1 225

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-477, REVISION 3 PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGES (MARK-UPS)

Control Room AC System B 3.7.4 BASES ACTIONS A-1 With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the unit in this condition, the remaining OPERABLE control room AC subsystem is adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in loss of the control room air conditioning function, The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate cooling methods.

B.1 and B.2 Ifboth control room AC subsystems are inoperable, the Control Room AC System may not be capable of performing its intended function.

Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore a Control Room AC subsystem to OPERABLE status. This Completion Time is reasonable considering that the control room temperature is being maintained within limits and the low probability of an event occurring requiring control room isolation.

83C.1 and 9C.2 In MODE 1, 2, or 3, if the inoperable control room AC subsystem(s) cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE that minimizes risk.

To achieve this status the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

GD.I and CD.2 During OPDRVs, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE control room AC subsystem may be placed Immediately in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected, Revision 73 Generating Station B 3.7,4-3 Columbia Generating Station B 3.7.4-3 Revision 73

Control Room AC System B 3.7.4 BASES ACTIONS (continued)

An alternative to Required Action CD.1 Is to immediately suspend I OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

04 A*

Ar M 1ooal U- O.-444 Canro:,R0-m A/"C.Syr;e-~ a0-181PE) F tho ~ritondod fuIw4+e~4~

E.1 During OPDRVs-w 4waiAG,eGob-eF& epertble if Required Actions BA and B.2 cannot be met within the required Completion Times, action must be taken to immediately suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analyses.

The SR consists of a combination of testing and calculation. The 24 month Frequency is appropriate since significant degradation of the Control Room AC System Is not expected over this time period.

REFERENCES 1. FSAR, Section 6.4.

2. FSAR, Section 9.4.1.

3. 10 CFR 50,36(c)(2)(ii),

Columbia Generating Station 8 3,7.4-4 Revision 73

v t e Letter Sequence Request
TAC:MF2528, Add Action for Two Inoperable Control Room AC Subsystems (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2013-09-23 [Table View]

ML13247A659